Privacy Policy

1. Introduction

The privacy notice of personalityOS (“we,” “us,” or “our”) demonstrates our dedication to safeguarding your privacy and the protection of your personal data. By using the personalityOS web app application (“the App”) or visiting www.personalityos.com (“our website”), regardless of your location, you will be informed about the manner in which we manage your personal data. This notice also outlines your privacy rights and the legal provisions that ensure your protection.

2. Important Information and Who We Are

The personalityOS product, developed by DING TECH LTD, is registered at 20 Wenlock Road, London, England, N1 7GU. We manage the website located at www.personalityos.com as well as the personalityOS web app application.

3. Purpose of This Privacy Notice

As mandated by data protection legislation, we must offer specific information about our identity, the methods we use to process personal data, the purposes behind it, and your rights concerning your personal data, along with instructions on exercising those rights. You can find this information in our Privacy Notice, and it is crucial that you read it.

We do not design our website or the App for children, nor do we intentionally gather data about them.

Please ensure you read this privacy notice in conjunction with any other privacy notices or fair processing notices we may supply during specific instances of collecting or processing your personal data. This will help you fully comprehend how and why we use your data. This privacy notice supplements, rather than overrides, any other notices.

4. Controller

personalityOS serves as the controller and assumes responsibility for personal data collected from you through our website and the Web App.

For inquiries about this privacy notice, including exercising your legal rights, please contact us using the information provided below.

5. Contact Information

To obtain further details, email us at: support@personalityos.com

If you are a data subject in the European Economic Area (“EEA”), you can file a complaint with your data protection supervisory authority at any time (in the United Kingdom (“UK”), this is the Information Commissioner’s Office (“ICO”) (www.ico.org.uk)). However, we would appreciate the opportunity to address your concerns before you contact a supervisory authority, so please reach out to us first.

6. Privacy Notice Updates and Your Responsibility to Inform Us of Changes

We routinely review our privacy policy. The latest update to this notice was on 27 November 2020.

It is crucial that we maintain accurate and up-to-date personal data about you. If your personal data changes during your association with us, kindly keep us informed.

7. Third-Party Links

Our website and the App may feature links to third-party websites, plug-ins, and applications. By clicking on these links or activating these connections, you may permit third parties to gather or disseminate data about you. We have no control over such third-party websites and do not assume responsibility for their privacy policies. Upon leaving our website, we advise you to review the privacy notice of each website you visit.

8. Data We Collect About You

Under EU legislation, personal data or personal information refers to any details about an individual that allows for their identification. It does not encompass data where the identity has been removed (anonymous data).

We may gather, utilize, store, and transfer various types of personal data about you, which we have categorized as follows:

Identity Data : first name, last name, username or similar identifier, title, date of birth, and gender.
Contact Data : billing address, email address, and telephone numbers.
Financial Data : bank account and payment card details.
Transaction Data : details about payments to and from you and other purchase details.
Technical Data : internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website and the App.
Profile Data : username and password, purchases or orders made by you, feedback, and survey responses (you may provide us with what is considered Special Categories of Personal – – Data through certain surveys, as discussed below).
Usage Data : information about how you use our website and the App.
Marketing and Communications Data : your preferences for receiving marketing from us and our third parties and your communication preferences.
Special Categories of Personal Data : details about your religious or philosophical beliefs (including your place of worship) and information about your physical and mental health. For further information, please refer to the section on Special Categories of Personal Data below.

We also gather, utilize, and share Aggregated Data, such as statistical or demographic data, for any purpose. Although Aggregated Data may be derived from your personal data, it is not considered personal data by law, as it does not directly or indirectly disclose your identity. For instance, we may aggregate your Usage Data to determine the percentage of users accessing a specific feature on the website and the App. By aggregating responses within the website and the App, we can offer church leaders a unique perspective on their church’s emotional and spiritual composition, aiding them in caring for their communities. No individual’s information is ever visible since all personal data is anonymized and combined with that of at least five other Web App users.

Nonetheless, if we merge or connect Aggregated Data with your personal data in a way that directly or indirectly identifies you, we will treat the combined data as personal data, which will be used according to this privacy notice.

9. Special Categories of Personal Data

Special Categories of Personal Data pertain to sensitive personal data that necessitates increased protection.

EU legislation defines Special Categories of Personal Data as personal data revealing racial or ethnic origin, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health information, and genetic and biometric data.

We gather details about your religious or philosophical beliefs (including your place of worship) and information about your physical and mental health to offer certain features of the website and the App. This information is typically used to grant access to additional features, although we may aggregate this information and utilize the aggregated results for other purposes (in which case it will become Aggregated Data).

To process Special Categories of Personal Data lawfully, fairly, and transparently, and to ensure compliance with the General Data Protection Regulation ((EU) 2016/279) (“GDPR”) principles and requirements, we must identify a lawful basis under Article 6 of the GDPR and a separate condition for processing under Article 9 of the GDPR.

Our lawful basis for processing Special Categories of Personal Data, as well as our condition for processing, is your explicit consent.

When you need to provide Special Categories of Personal Data to access certain functions of the website and the App, we must obtain your explicit consent on the relevant page. You will be asked to read and accept the following statement by ticking a box before accessing those specific functions:

“I understand that to access certain functions of this website and App, I must provide personalityOS with sensitive personal information about my religious or philosophical beliefs (including my place of worship) and information about my physical and mental health (Special Categories of Personal Data).

I understand that under EU data protection laws, processing Special Categories of Personal Data requires a higher level of protection, and that explicit consent to the processing of Special Categories of Personal Data is one lawful basis and condition for processing.

By ticking this box, I consent to personalityOS collecting, using, storing, and transferring my Special Categories of Personal Data in accordance with personalityOS’s Privacy Notice.”

Please note that if you do not provide explicit consent for us to process Special Categories of Personal Data, we will be unable to offer all functions of the website and the App to you.

10. Failure to Provide Personal Data

If we are required to collect personal data by law or under a contract we have with you, and you do not provide that data when requested, we may be unable to fulfill the contract we have or are attempting to establish with you (e.g., providing access to the website and/or App). In this situation, we might need to cancel your account, but we will inform you if this occurs.

11. Methods of Personal Data Collection

We employ various methods to collect data from and about you, including:

Direct Interactions : You may provide us with your Identity, Contact, and Financial Data by completing forms or corresponding with us via email or through the App. This includes personal data you submit when logging into our App.
Automated Technologies or Interactions : When interacting with our website and App, we may automatically gather Technical Data about your equipment, browsing actions, and patterns.
Third Parties or Publicly Available Sources : We may receive personal data about you from different third parties, as detailed below:

Technical Data from analytics providers like Google, based outside the EU.
Contact, Financial, and Transaction Data from technical and payment service providers, such as Stripe, Inc., based outside the EU.
Identity Data, Profile Data, Usage Data, and Contact Data from mobile application providers, such as Google and Apple.

12. Using Your Personal Data

We will use your personal data only when permitted by law. Typically, we use your personal data in these circumstances:

When we need to perform a contract with you, such as providing access to the website and the App.
When it is necessary for our legitimate interests (or those of a third party), and your interests and fundamental rights do not override those interests (e.g., managing our records, developing, and enhancing our website and the App).
When we need to comply with legal or regulatory obligations.

Please refer to the Glossary at the end of this privacy notice for more information on the lawful bases we rely on to process your personal data.

We generally do not depend on consent as a legal basis for processing your personal data. However, we will:

Rely on consent as a legal basis for processing Special Categories of Personal Data to provide access to the website and the App. To allow us to collect and process this type of information, you must give your consent using the opt-in button on the relevant page of the website and the App. For more information, please see the section on Special Categories of Personal Data above.
Obtain your consent before sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

13. Cookies

Currently, our website and the App do not use cookies. However, if we decide to use cookies in the future, we will notify you.

14. Marketing

We aim to give you options regarding certain personal data uses, especially in marketing and advertising. We have established these personal data control mechanisms.

15. Promotional Offers from Us

We may use your Identity, Contact, Technical, Usage, and Profile Data to determine what we believe may interest you or fulfill your needs. This helps us identify relevant products and offers for you (known as marketing).

You will receive marketing communications from us if you have requested information, downloaded the App, or purchased a subscription, and have not opted out of receiving marketing.

16. Third-Party Marketing

We will obtain your explicit opt-in consent before sharing your personal data with any third party for marketing purposes.

17. Opting Out

You can request that we or third parties stop sending you marketing messages at any time by following the opt-out links in any marketing message sent to you or by contacting us at any time.

18. Change of Purpose

We will use your personal data only for the purposes we initially collected it for, unless we reasonably determine that we need to use it for another reason that is compatible with the original purpose. If you would like an explanation of how processing for the new purpose is compatible with the initial purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis that allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where required or permitted by law.

19. Disclosure of Your Personal Data

You agree that we have the right to share your personal information with selected third parties, including:

Business partners, suppliers, and subcontractors, including data storage centers, for the performance of any contract we enter into with them or you; and
Analytics and search engine providers that assist us in improving and optimizing our website and the App.

We will disclose your personal information (disclosing only the minimum necessary amount) to third parties:

If we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets;
If personalityOS or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; or
If we are under a duty to disclose or share your personal data to comply with any legal obligation, or to enforce or apply our terms of use and other agreements, or to protect the rights, property, or safety of personalityOS, our customers, or others. This includes exchanging information with other companies and organizations for fraud protection purposes.

We require all third parties to respect the security of your personal data and treat it according to the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

20. International Transfers

We may transfer your data within the EEA, but we do not transfer your personal data outside of the EEA.

21. Data Security

We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered, or disclosed. Additionally, we restrict access to your personal data to employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data based on our instructions and are subject to a duty of confidentiality.

We have established procedures to address any suspected personal data breach and will notify you and any applicable regulator of a breach when legally required to do so.

22. Data Retention

We retain your personal data only as long as necessary to fulfill the purposes for which it was collected, including satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may keep your personal data for a longer period in case of a complaint or if we reasonably believe there is a prospect of litigation concerning our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data; the potential risk of harm from unauthorized use or disclosure of your personal data; the purposes for processing your personal data and whether we can achieve those purposes through other means; and the applicable legal, regulatory, tax, accounting, or other requirements.

In some circumstances, you can request that we delete your data. See “Your Legal Rights” below for more information.

In some cases, we will anonymize your personal data (so it can no longer be associated with you) for research or statistical purposes. In these cases, we may use this information indefinitely without further notice to you.

23. Your Legal Rights

Under certain circumstances, you have the following rights under data protection laws regarding your personal data:

Request access to your personal data (also known as a “data subject access request”). This allows you to receive a copy of the personal data we hold about you and verify that we are processing it lawfully.
Request correction of the personal data we hold about you. This allows you to have any incomplete or inaccurate data we hold about you corrected. We may need to verify the accuracy of the new data you provide.
Request erasure of your personal data . This allows you to ask us to delete or remove personal data when there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your personal data if you have successfully objected to processing, if we processed your information unlawfully, or if we must erase your personal data to comply with local law. However, we may not always be able to comply with your erasure request for specific legal reasons, which we will notify you of, if applicable, at the time of your request.
Object to processing your personal data when we rely on a legitimate interest (or a third party’s) and your particular situation makes you want to object to processing, as you feel it impacts your fundamental rights and freedoms. You also have the right to object when we process your personal data for direct marketing purposes. In some cases, we may demonstrate compelling legitimate grounds to process your information that override your rights and freedoms.
Request restriction of processing your personal data . This allows you to ask us to suspend processing your personal data in these scenarios: (a) if you want us to establish the data’s accuracy; (b) if our use of the data is unlawful but you do not want us to erase it; (c) if you need us to hold the data even if we no longer require it to establish, exercise, or defend legal claims; or (d) if you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or a third party . We will provide your personal data in a structured, commonly used, machine-readable format to you or a third party you choose. This right only applies to automated information you initially provided consent for us to use or information we used to perform a contract with you.
Withdraw consent at any time when we rely on consent to process your personal data . This will not affect the lawfulness of processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will inform you if this is the case when you withdraw your consent.

To exercise any of these rights, please either use the App’s functionality (if applicable) or contact us using the provided details. You can request an electronic copy of the information you provided through the App or the deletion of your personal data by contacting us.

24. No Fee Usually Required

Accessing your personal data or exercising any of your other rights typically does not require a fee. We may charge a reasonable fee for clearly unfounded, repetitive, or excessive requests. In such cases, we might also refuse to comply with your request.

25. What We May Need from You

To confirm your identity and ensure your right to access your personal data (or exercise any other rights), we may request specific information from you. This security measure prevents personal data from being disclosed to unauthorized individuals. We may also contact you to request additional information to expedite our response.

26. Time Limit to Respond

We aim to respond to all legitimate requests within one month. If your request is complex or you have submitted multiple requests, it may take longer than a month. In such cases, we will notify you and keep you updated.

27. Glossary

Lawful Basis:

“Legitimate interest” : Our business’s interest in conducting and managing our operations to provide the best service/product and the most secure experience. We ensure that we consider and balance any potential impact on you (positive or negative) and your rights before processing your personal data for our legitimate interests. We do not use your personal data for activities where the impact on you overrides our interests, unless we have your consent or are required or permitted by law. You can obtain more information about how we assess our legitimate interests against any potential impact on you by contacting us.

“Performance of contract” : Processing your data when necessary for the performance of a contract you are a party to or taking steps at your request before entering into such a contract.

“Comply with a legal obligation” : Processing your personal data when necessary for compliance with a legal obligation to which we are subject.

“Suggested Text” : When visitors leave comments on the site, we collect the data displayed in the comments form, as well as the visitor’s IP address and browser user agent string to help with spam detection.

An anonymized string (hash) created from your email address may be provided to the Gravatar service to check if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/ . Once your comment is approved, your profile picture becomes publicly visible in the context of your comment.

DING TECH LTD, 20 Wenlock Road, London, England, N1 7GU